Article
IRS Guidance Clarifies Tax Treaty Benefits On Branch Profits Tax For Funds And Multinationals Using Reverse Hybrids
In Chief Counsel Advice AM 2025-002 (dated Sept. 8, 2025; released Sept. 19, 2025) (Memorandum), the IRS analyzed how U.S. income tax treaties apply to the branch profits tax...
Greenberg Traurig, LLP